• Analysis of CMS’ 2013 ESRD Quality Incentive Program, bundled payment

    On Nov. 2, the Centers for Medicare & Medicaid Services released its final rule for the End-Stage Renal Disease Prospective Payment System for 2013 and the Quality Incentive Program for payment year 2015. The agency had released a draft on July 2 for commentary; this final rule takes effect Jan. 1. (From NNI Nov 28, 2012)

    The regulation governs:

    • How much dialysis clinics get paid in 2013 via Medicare’s bundled payment system
    • What quality and reporting measures dialysis providers must follow in 2013. How clinics do in meeting these measures next year will impact how much they get paid in 2015.

    The complete rule can be downloaded as a PDF here.

    New reporting and clinical measures for QIP 2013/2015 include:

    • (Reporting) Anemia management. CMS wants to pay closer attention to how clinics use anemia drugs.
    • (Clinical) Adequacy. This measure has been modified––replacing the urea reduction ratio measurement for adequacy with the Kt/V measurement––and expanded to include adult peritoneal dialysis patients and pediatric in-center hemodialysis patients.

    Other reporting and clinical measures adopted in 2012 remain in the QIP, including reporting measures for patient satisfaction, dialysis events, and infection control, and a clinical measure for vascular access type. It also:

    • Expands the reporting requirements for dialysis events from three months to 12 months.
    • Requires that at least 96% of patients evaluated by the mineral metabolism reporting measure must be monitored on a monthly basis for serum calcium and serum phosphorus levels, which applicable for payment year 2014. These patients must also have had at least been dialyzed seven times by the facility.
    • Changes the In-Center Hemodialysis Consumer Assessment of Healthcare Providers and Systems (ICH CAHPS) patient survey reporting measure. CMS agreed to have this measure applicable only for clinics with 11 patients or more. It acknowledged comments from providers in its final rule that the survey was lengthy and cumbersome, but added that it will eventually move this measure from a reporting only to a clinical measure.

    The PPS, or bundled paymentFor 2013, CMS has set the ESRD base rate to $240.36. The amount reflects the application of the ESRD bundled market basket reduced by the productivity adjustment, or 2.3%, and the wage index budget-neutrality adjustment factor of 1.000613 to the 2012 ESRD PPS base rate of $234.81, giving clinics a $5.55 per treatment raise. CMS made no changes to the methodology used to compute the drug add-on for the bundle and only updated the data used to calculate the amount. CMS maintained the $20.33 per treatment drug add-on amount for 2013.

    ESRD wage index and wage index floor For 2013, CMS is reducing the wage index floor from 0.550 to 0.500, as part of a gradual phase-out of this measure. The AY modifier, which can be added to claims for drugs and laboratory tests that are not ESRD related to allow for separate payment, stays in place. But the agency emphasized that it is continuing to monitor how it is used. “We also indicate that we may consider eliminating the AY modifier in future rulemaking if we believe that the AY modifier is not being used for the purpose intended,” CMS wrote. Clinics can for the first time use the AY modifier in 2013 to seek separate payment for daptomycin.

    Dialysis providers will also have to accept changes in what CMS allows for bad debt. The change is Congressionally mandated, coming from The Middle Class Tax Extension and Job Creation Act of 2012. The agency is reducing allowance for bad debt from 100% to 88% in 2013, and then down to 76% in 2014, and 65% in 2015 and subsequent years.